JSC ET&S Personal Data Policy.
Legal and business address of JSC ET&S: 16 Golubinskaya Street, Moscow, 117574, Russia
Purpose and scope of the document
JSC ET&S (hereinafter – Company) Personal Data Policy (hereinafter – Policy) defines the position and intentions of the Company with regard to the processing and protection of personal data with the purpose of protecting freedoms and rights of each individual, in particular, the right to privacy, the right to family privacy, the right to a good name and reputation.
The Policy shall be followed strictly and rigorously by all executives and employees of all divisions of JSC ET&S.
The Policy applies to all personal data of subjects processed by the Company with and without the use of computerized equipment.
Any subject shall have access to this Policy.
Personal data is any information that can directly or indirectly refer to an identifiable individual (citizen). Specifically, such data can include, without limitation: full name; year, month, and day of birth; address; information about social or wealth status, educational background, employment history, income, health, and other information.
Processing of personal data is any action (activity) or a set of actions (activities) applied to personal data involving the use of computer equipment or without it. Such actions (activities) include: collecting, obtaining, recording, systematizing, accumulating, storing, specifying (updating, changing), extracting, using, transferring (distributing, presenting, giving access to), redacting, blocking, deleting, and destroying personal data.
JSC ET&S processes personal data of the following subjects:
employees of JSC ET&S;
subjects that have signed legally binding contracts with the Company;
candidates for job openings at JSC ET&S;
customers of JSC ET&S;
registered users of the JSC ET&S website;
representatives of legal entities;
suppliers (individual entrepreneurs).
Terms and Conditions of Processing of Personal Data
- JSC ET&S takes security of personal data to mean protection from illegal or random access, destroying, changing, blocking, copying, presenting, distributing this personal data and other illegal actions in relation to the personal data, and shall take all necessary legal, organizational, and technical steps to ensure the protection of personal data.
- JSC ET&S processes and protects personal data in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-FZ "On Personal Data," subordinate acts, other federal laws of the Russian Federation determining cases and terms of processing personal data, directives and guidelines of FSTEC and FSB.
- JSC ET&S follows these principles in the processing of personal data:
- legality and justice;
- restriction of processing personal data for concrete, legal purposes set in advance;
- prohibition of processing personal data that does not comply with the purposes of collecting personal data;
- prohibition of merging databases that contain personal data, that can be processed for inadequate purposes;
- processing personal data that meets its purposes;
- meeting the content.
- The Company shall process personal data only if at least one of the following conditions is met:
- the subject of personal data has agreed to his or her personal data being processed;
- the processing of personal data is necessary to achieve the goals as provided by the law, to perform the functions, powers, and liabilities imposed on the operator by the legislation of the Russian Federation.
- the processing of personal data is necessary to satisfy an agreement if one of its parties, beneficiaries, or bondsmen is the subject of personal data, or to conclude an agreement initiated by the subject of personal data or an agreement that would make the subject of personal data its beneficiary or bondsman;
- the processing of personal data is necessary to protect the rights and legal interests of the Company or third parties or to achieve socially important goals granted that the rights of the subject of personal data will not be infringed;
- the subject of personal data has granted access to his or her personal data to an unlimited range of individuals or the processing is performed at his or her request;
- the personal data processed is subject to being publicly disclosed in accordance with the federal law.
- JSC ET&S reserves the right to authorize a third party to process the personal data on the grounds of a signed contract. The parties that JSC ET&S entrusted with the processing of personal data shall follow the rules and principles of protecting personal data as provided by Federal Law No. 152-FZ "On Personal Data." For each party, there shall be a list of actions (activities) with personal data that shall be performed by the legal entity entrusted with the processing of personal data, as well as of purposes of the processing; such party shall be legally bound to guarantee the protection of personal data in processing, and there will be a list of requirements for protection of the processed personal data.
- JSC ET&S reserves the right to hand over personal data in the cases determined by the legislation of the Russian Federation.
- For information purposes, the Company has the right to create public sources of personal data of its employees, including manuals and address books. With the consent of the employee, the Company can include his or her first name, last name, patronymic, date and place of birth, job title, contact numbers, and email in such publicly available datasets. All the information about the employee shall be removed from a publicly available dataset at any moment at the employee's demand or by a ruling of a court or any other authorized government agency.
- The Company shall destroy or redact personal data once the processing has achieved its purpose or if there is no more need to pursue that purpose.
- Rights of the Subject of Personal Data
The citizen whose personal data is processed by JSC ET&S has the right to:
- receive the following information from JSC ET&S:
- confirmation of the processing of personal data by JSC ET&S;
- legal grounds and purposes of the processing of personal data;
- information about methods that JSC ET&S uses to process personal data;
- the name and address of JSC ET&S;
- information about entities with access to personal data or to whom personal data can be disclosed pursuant to the agreement with JSC ET&S or the federal law;
- the list of processed personal data related to the citizen who has sent the request and their source, if a different order of presenting such information is not provided by the federal law;
- information about the time of processing of personal information, including the storage period;
- the procedure for exercising rights of the citizen as provided by Federal Law No. 152-FZ "On Personal Data";
- information about an actual or suggested cross-border handover of personal information;
- the name and address of the entity entrusted by JSC ET&S with the processing of personal data;
- other information as provided by Federal Law No. 152-FZ "On Personal Data" or other federal laws;
- demand that their personal data be updated, blocked, or destroyed if the personal data is incomplete, outdated, inaccurate, obtained illegally, or is not required to achieve the declared purpose of processing;
- call off his or her consent to the processing of personal data;
- demand that JSC ET&S prevent any improper actions in relation to his or her personal data;
- file a complaint against JSC ET&S for their actions or inaction to the Federal Service for Supervision in the Sphere of Telecom, Information Technologies and Mass Communications (Roskomnadzor) or to the court if the citizen believes that JSC ET&S processes his or her personal data in violation of Federal Law No. 152-FZ "On Personal Data" or infringes his or her rights in any other way;
- protect his or her rights and legal interests, including to compensate losses and/or non-economic damage by a court ruling.
In case of the violation of this Policy, JSC ET&S shall incur liability in accordance with the current legislation of the Russian Federation.
For more information about the processing of personal data, reach out to us personally at JSC ET&S or send an official request via Russian Mail at: 16 Golubinskaya Street, PO box 9, Moscow, 117574, Russia
In case of an official request, please include the following in the body of your request:
- full name;
- number of the identification document of the subject of personal data or his or her representative, date of issue and the issuing agency details;
- confirmation of your relation to JSC ET&S or any confirmation of the fact that JSC ET&S processes your personal data;
- signature of the citizen (or his or her legal representative). If the request is sent electronically, it must be in the form of an electronic document signed with an electronic signature in accordance with the legislation of the Russian Federation.
You can find the latest version of JSC ET&S Personal Data Policy at www.more-on.ru.
Information about requirements for the protection of personal data implemented by JSC ET&S. JSC ET&S takes all the required legal, organizational, and technical measures to protect personal data from illegal or random access, destroying, changing, blocking, copying, presenting, distributing this personal data and other illegal actions in relation to the personal data.
In accordance with Federal Law No. 152-FZ "On Personal Data" such measures include:
- identifying threats to the security of personal data when processing it in electronic systems;
- taking organizational and technical measures to ensure the security of personal data when processing it in electronic personal data systems necessary to meet the requirements for the protection of personal data, according to the levels of protected personal data established by the Government of the Russian Federation.
- taking measures of protecting data that have been deemed fit through the established evaluation procedure;
- evaluating the efficiency of the personal data protection measures before putting an information system of personal data into operation;
- identifying instances of illegal access to personal data and taking corresponding measures;
- restoring personal data that has been modified or destroyed as a result of unauthorized access;
- establishing rules of access to personal data processed in an electronic personal data system as well as recording all actions applied to personal data in an electronic personal data system;
- overseeing the measures taken to protect personal data and the protection level of electronic personal data systems;
- recording all carriers of personal data;
- establishing an access control procedure at the Company;
- locating equipment for the processing of personal data on secured and guarded premises;
- maintaining security equipment and alarms;
- monitoring user actions, investigating violations of the personal data protection requirements
In order to coordinate efforts to protect personal data, JSC ET&S appointed individuals in charge of the protection of personal data.